JUAN GARCIA vs. CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION
The Workers' Compensation Appeals Board denied the CCPOA Benefit Trust Fund's petition for reconsideration. The lien claimant sought penalties, alleging bad faith because the defendant sent an award payment directly to the lien claimant instead of its hearing representative. The Board found no evidence of unreasonable delay, noting the payment was timely sent to the address on file and promptly cashed by the lien claimant, constituting substantial compliance. The Board also suggested the lien claimant's multiple claims and penalty requests, despite timely payment, could constitute bad faith.